SecProbe.io

September 25, 2025
Fahmi W. Karam
Chief Financial Officer
Upbound Group, Inc.
5501 Headquarters Drive
Plano, Texas 75024
Re:Upbound Group, Inc.
Form 10-K for Fiscal Year Ended December 31, 2024
Filed February 25, 2025
Form 10-Q for Fiscal Period Ended June 30, 2025
Filed July 31, 2025
File No. 001-38047
Dear Fahmi W. Karam:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-Q for Fiscal Period Ended June 30, 2025
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Analysis of Cash Flow, page 36
1.Please quantify all factors cited, pursuant to the guidance noted above, so investors
may understand their relative magnitude. Additionally, explain to us and disclose how
and why the cited factor of the acquisition of Brigit positively impacted operating
cash flows, despite a decrease in consolidated net income inclusive of the acquisition.
Further, discuss the underlying factor(s) associated with the timing of vendor
payments, for example, the reason for timing impacts. Refer to the guidance noted
above.

September 25, 2025
Page 2
Form 10-K for Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Analysis of Cash Flow, page 47
2.You attribute the decrease in reported cash provided by operating activities in fiscal
2024 compared to fiscal 2023 of $95.6 million solely to an increase in your inventory
purchases, which appears to be about $57 million based on the change between 2024
and 2023 in the line Rental Merchandise reported in the statement of cash flows.
Based on changes in amounts reported in the statement of cash flows, it appears other
factors materially affected the change in operating cash flows between these periods
that have not been discussed. For example, net earnings/loss, adjusted for adjustments
to reconcile net earnings (loss) to net cash provided by operating activities,
increased $120 million, negative impact in the sum of receivables, accounts payable-
trade and accrued liabilities aggregating $157 million and increase in income taxes
paid, net of refunds, of $34 million. Refer to item 303(b) and all applicable
instructions to paragraph (b) regarding analysis of material changes in line items from
period to period. Also refer to the introductory paragraph of section IV.B and all of
B.1 of Release No. 33-8350 regarding the content of the analysis. Additionally, refer
to section III.D of Release No. 33-6835 (501.04 of the staff’s Codification of
Financial Reporting) regarding quantification of factors cited. Please revise your
analysis as appropriate.
Notes to Consolidated Financial Statements
Note T - Segment Information, page 89
3.Pursuant to ASC 280-10-50-29, please tell us and disclose to state the specific
segment measure(s) of profit or loss used by your CODMs to assess performance and
allocate resources. Also refer to ASC 280-10-55-47.b.
4.For each segment you present revenues and gross profit. It appears cost of revenues
for each segment may be easily computable and a significant expense. Please tell us
how your disclosure complies with the requirement to disclose easily computable
significant segment expenses pursuant to ASC 280-50-10-26A.
5.Please reconcile the total of the reportable segments' amount for each measure of
profit or loss to your consolidated income/loss before income taxes and discontinued
operations or consolidated net income/loss as appropriate. Refer to ASC 280-10-50-
30.b.
            In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.

September 25, 2025
Page 3
            Please contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services